Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Validity of Best judgment assessment - Assessment u/s 153C - since petitioner has filed a return, no best judgment assessment u/s 144 of the Act could have been passed - So far as, the provisions of Section 144(1)(b) of the Act are concerned, as explained hereinabove, there has been no failure to comply with the terms of any notice issued under Section 142(1) of the Act. Therefore, the purported exercise of powers u/s144 of the Act cannot be sustained. - HC
Validity of Best judgment assessment - Assessment u/s 153C - since petitioner has filed a return, no best judgment assessment u/s 144 of the Act could have been passed - So far as, the provisions of Section 144(1)(b) of the Act are concerned, as explained hereinabove, there has been no failure to comply with the terms of any notice issued under Section 142(1) of the Act. Therefore, the purported exercise of powers u/s144 of the Act cannot be sustained. - HC
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